The Association of Retail Travel Agents (ARTA) posts its complete and absolute
opposition to the International Air Transport Association (IATA) proposal to administer
the “.travel” Top Level Domain (TLD) name.
Our 4,500 independent travel retailers
around the United States and Canada join the 3,000 members of the Association of
Canadian Travel Agents (ACTA), the 1,000 members of the U.S. Travel Agent Registry
(USTAR), and the 5,500 members of the Outside Sales Support Network
their expressed opposition to the IATA proposal.
Simply put, there’s no question
that IATA’s plans violate ICANN’s criteria for assessing TLD proposals – most notably,
the long-term “proof of concept” goal for introducing TLDs, enhanced
for registration services, greater diversity in the domain name system, and (most
important) the appropriate protection of the rights of others in connection with
the operation of
Specifically, we oppose the IATA proposal on the following
1. IATA does not represent a diverse cross-section of the
global travel community.
IATA’s proposal belies its true legal structure.
IATA’s essential purpose is to represent the business interests of 275 airlines in
143 countries and territories around the world. In practical terms, IATA functions
as an airline cartel.
Despite IATA’s assurances to the contrary, the many other
segments of the global travel community deeply interested in the “.travel” TLD –
travel agents, airports, bus and motorcoach operators, hotels and resorts, bed-and-breakfast
inns, campgrounds, cruise lines, car rental
companies, railroads, tour operators,
sightseeing companies, tourist boards and destination marketing organizations, ferry
and taxi operators, travel insurance providers, consumer travel advocates, travel
guide publishers, and travel technology companies – have no legal standing or voice
within IATA and, therefore, no legal guarantee of access to or impartiality in the
administration of the TLD.
2. IATA has already demonstrated its unwillingness
to remain impartial in its administration of the TLD.
IATA promises in its proposal
to establish an administration scheme, supplemented by an Advisory Committee and
a Registrars Forum, to guarantee the impartial assignment and review of domain names
under the TLD to applicants.
Before this current comment period closes, in fact,
IATA has already proved its willingness to grant special privileges to selected travel
industry players in the name of political expediency. On 18 October, the American
Society of Travel Agents (ASTA) issued a statement opposing IATA’s plans, saying
“[i]t is completely inappropriate for an international cartel to control segments
of the Internet, especially when the competitive interests of the members of the
may be involved.” This week, IATA announced a “compromise” in which
ASTA removed its opposition to the plan in return for a seat on “the .travel Board”
and automatic qualification for ASTA agents seeking a “.travel” name in the future.
IATA promises in its proposal to make the TLD available only to businesses that can
meet “objective and transparent criteria which establish their legitimacy as reputable
providers of travel-related products, services and information,” IATA has already
cut this deal (and, perhaps, others not yet public) to grant wholesale automatic
approvals for TLD requests in return for silence from its critics.
To ARTA, that
heavy-handed practice demonstrates conclusively that IATA is not qualified to administer
the TLD impartially.
3. IATA represent a segment of the global travel
community with an established history of market dominance, particularly in the electronic
IATA is governed, and its coffers are funded, by airlines that have
an extremely spotty record of anticompetitive behavior, alleged collusion, and outright
antitrust law violations in the United
States, Canada, and the European Union,
as well as other global jurisdictions.
IATA currently administers and enforces
a global accreditation and settlement scheme that answers to no authority except
IATA’s member carriers, and IATA has taken specific steps in recent years to block
the introduction of competing accreditation and settlement schemes
by non-airline interests.
In the 1990s, our association filed a formal legal complaint
against IATA with the U.S. Department of Transportation to block IATA’s launch of
a discount airfare Web site that threatened to violate U.S. antitrust laws.
IATA abandoned its plans in the face of growing
members effectively control the global computer reservation system (CRS) marketplace
via their ownership interests in the major CRS companies – to the extent that the
United States is currently reviewing its CRS regulations in an attempt to break this
stranglehold and introduce much-needed competition in this electronic arena.
on the anticompetitive track record of IATA and its member airlines, should ICANN
feel comfortable in entrusting the “.travel” TLD to their care?
We request respectfully
that ICANN choose instead a future applicant for this TLD who can provide evidence
of the ability and the willingness to administer “.travel” in a fair, unbiased manner,
with full participation from the entire global travel community.
John K. Hawks,
Association of Retail Travel Agents
2692 Richmond Road, Suite
Lexington, KY 40509-1542 U.S.A.